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clear that if she did not abide then she would suffer serious financial and reputational harm), through the end of 2013. 115. James "Jes" Staley ("Staley"), the then-head of JP Morgan's private banking division, was a regular visitor of Epstein's during that period of time, through and beyond 2013, a
e an intentional decision to keep Epstein on as a client. 217. JP Morgan, including its CEO Jamie Dimon and the highest levels of the bank, knew of Jes Staley's personal involvement with Epstein and yet still allowed Staley to remain a decision maker for JP Morgan on Epstein accounts. 218. Even before the s
f 130 75. In addition to coercing commercial sex acts from his victims, Epstein also committed coercive sexual offenses against them as defined in New York Penal Law § 130, as described in greater detail below. 76. Throughout around 1998 through about July 2019, the Epstein's sex- trafficking venture recrui
ned multiple residences and frequently travelled between them, including at 9 East 71' Street, New York, New York 10021, and at 49 Zorro Ranch Road, Stanley, New Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively valued his New York townhome at $55,931,000.0
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
wned multiple residences and frequently travelled between them, including at 9 East 7P Street, New York, New York 10021, and at 49 Zorro Ranch Road, Stanley, New Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively valued his New York townhomc at $55,931,000.0
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
ned multiple residences and frequently travelled between them, including at 9 East 71' Street, New York, New York 10021, and at 49 Zorro Ranch Road, Stanley, New Mexico 87056, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively valued his New York townhome at $55,931,000.0
touched Plaintiff in an offensive and sexual manner without her consent. 81. Epstein and Maxwell's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to forcible touching as defined in Article 130.52, inasmuch as Epstein and Maxwell intentionally and for
Entities connected to both Jes Staley and New York Penal

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
New York
LOCATION
Les Wexner
PERSON
David Boies
PERSON
Palm Beach
LOCATION
Southern District of New York
ORGANIZATION
United Kingdom
LOCATIONSigrid McCawley
PERSON
Martha Stewart
PERSON
New Mexico
LOCATION
Kenneth Marra
PERSON
Jay Lefkowitz
PERSONN.Y. Post
ORGANIZATION
Edward Jay Epstein
PERSON
Alaska
LOCATION